Case Summary (G.R. No. L-9805-06)
Incident Overview
On the afternoon of May 20, 1955, Rufo Verano heard commotion indicating that Dionisio Mabong was acting violently. Armed with a club, Verano approached the scene and witnessed Mabong stabbing Cipriano Tabel with a bolo. Verano demanded Mabong drop the weapon, but upon refusal, he struck Mabong, causing him to stumble. Verano then restrained Mabong, seized the bolo, and transported him on a small boat to deliver him to local law enforcement.
Legal Proceedings Initiated
On May 23, 1955, following an investigation, Mabong was charged with murder in two separate informations presented by the chief of police to the Justice of the Peace of Lianga. During preliminary investigation, Mabong pleaded guilty, leading to the transfer of the cases to the court of first instance.
Motion to Quash and Habeas Corpus Petition
Subsequently, Mabong filed a motion to quash the charges along with a petition for habeas corpus. His primary argument hinged on the assertion that his detention was illegal since authorities failed to present him before judicial authorities within the legally mandated period of eighteen hours, as set forth in Article 125 of the Revised Penal Code. Mabong contended that the subsequent filing of charges did not validate his initial unlawful detention.
Relevant Legal Provisions
Article 125 of the Revised Penal Code delineates penalties for public officials who fail to deliver detained persons to the proper judicial authorities within specified periods based on the gravity of the crime. Specifically, it mandates an eighteen-hour timeframe for serious crimes. While it allows for potential criminal liability against the detaining officer, the law does not state that an indictment for an offense becomes invalid due to such illegal detention.
Court’s Rationale on Detention Validity
The court found that although Mabong was detained for more than three days before charges were formally filed, the lack of a warrant for his arrest did not impact the legality of his confinement. Importantly, once criminal charges were filed, his detention became lawful. The court emphasized that resolving the potential illegality of the detention through a quashal of the information would serve little purpose, as it would necessitat
...continue readingCase Syllabus (G.R. No. L-9805-06)
Case Overview
- The case involves Dionisio Mabong, who was charged with murder following an incident on May 20, 1955, in Rizal, Lianga, Surigao.
- Rural policeman Rufo Verano witnessed Mabong attacking Cipriano Tabel with a bolo.
- Verano intervened, subdued Mabong, and brought him to local authorities, resulting in the filing of murder charges.
Incident Details
- On the afternoon of May 20, 1955, a commotion arose as Dionisio Mabong was reported to have gone berserk.
- Rufo Verano, armed with a club, responded to the cries and observed Mabong stabbing the victim, Cipriano Tabel.
- Verano attempted to stop Mabong, who resisted and was eventually clubbed on the face, causing him to fall.
- Verano apprehended Mabong, confiscated the bolo, tied him with a rope, and transported him by boat to Lianga's police chief.
Legal Proceedings
- On May 23, 1955, after an investigation, Mabong was charged with murder in two separate informations by the chief of police.
- During the preliminary investigation, Mabong pleaded guilty, leading to the forwarding of the cases to the